Exxon Chemical Patents, Inc., Exxon Corporation and Exxon Research and Engineering Co. v. Lubrizol Corporation

NIES, Circuit Judge,

dissenting.

Contrary to conventional wisdom in the art, Exxon discovered that small amounts of copper in automobile motor oil acts as an antioxidant, and it developed a highly successful commercial product using that discovery. The record discloses that Lubrizol learned of the presence of copper in Exxon’s motor oil from Exxon’s U.K. patent application and used the disclosure to prepare a competitive product. Both companies now use copper in the vast majority of their passenger car motor oil formulations. Following this phase of the litigation finding Lubrizol liable for infringement of Exxon’s U.S. Patent No. 4,867,890, Exxon was awarded $48,-000,000 in damages which were doubled for willfulness and $8,700,000 in interest plus $23,700,000 in attorney fees.1

The issue of infringement essentially comes down to whether Exxon drafted a claim in its U.S. patent that covers its invention. The majority interprets the claims to require that each of the listed additives to a motor oil must retain its pre-mix identity, to the extent that each must be present in the claimed proportions at some point after mixing. Because Exxon failed to prove that the additives remained identifiable (in those proportions) in Lubrizol’s product at some time during or after mixing, the majority reverses the judgment of infringement. I agree with the trial court that Lubrizol infringes. Lu-brizol’s motor oil contains the required additives in the required amounts. To hold that the final product does not “comprise” those ingredients because of their possible reaction with each other upon mixing seems to me nothing short of double speak. The claims can be interpreted as the majority does only by reading them in isolation from the context of the patent. Moreover, the majority’s interpretation gratuitously provides grounds for invalidation of the patent under section 112, because the specification does not describe nor enable one skilled in the art to make a product containing the claimed ingredients in the claimed amounts except as starting ingredients, not mixed ingredients.2

The majority focuses principally on the claimed “ashless dispersant” which must remain in its view “ashless” in the required amount in the composition. I interpret “ash-less dispersant” as simply the name or designation of an ingredient required as one of the *1564additives. It does not mean the ingredient must remain inert.

As stated in Adams v. United States, 383 U.S. 39, 49, 86 S.Ct. 708, 713, 15 L.Ed.2d 572, 148 USPQ 479, 482 (1966), “it is fundamental that claims are to be construed in light of the specifications and both are to be read with a view to ascertaining the invention.” Moreover, claims should be “construed, if possible, as to sustain their validity.” North American Vaccine, Inc. v. American Cyanamid Co., 7 F.3d 1571, 1577, 28 USPQ2d 1333, 1337 (Fed.Cir.1993).

Applying those precepts warrants an affir-mance in this case. My concern is, however, not merely this case. The majority mandates technical rules for how chemical compositions must be claimed which I reject.

I.

Infringement here turns on interpreting claims 1 and 61. Claim 1 is directed to “a lubricating oil composition” comprising: (a) a major amount of lubricating oil; (b) a specified amount of dispersant (either about 1-10 wt. percent of an ashless dispersant3 or about 0.3-10 wt. percent of a “polymeric viscosity index improver”4); (c) about 0.01 to 5.0 parts by weight of zinc dihydrocarbyl dithiophosphate (“ZDDP”); (d) about 5 to about 500 parts per million by weight of added copper in the form of an oil soluble copper compound; and (e) a calcium or magnesium detergent. Claim 61 claims a “lubricating oil concentrate composition” comprising the same five ingredients in different, specified amounts.

The trial judge interpreted those claims for the jury, instructing them as follows:

I instruct you that Exxon’s claims cover the ingredients which go into the composition. If you find that a Lubrizol product is made by using the starting ingredients in the amounts called for in one or more of Exxon’s claims, then that product directly infringes.

Lubrizol argues that that instruction is wrong. It maintains that, regardless of what ingredients are mixed together, there is infringement only if the final lubricant composition contains the five claimed ingredients, in the claimed amounts. Thus, although it is essentially uncontested that Lubrizol adds ashless dispersant and the other claimed ingredients in the claimed amounts to its motor oil, Lubrizol argues that there is no infringement because it was not proved that “ash-less” dispersant, in the claimed amount, was present in its final products. Specifically, it urges, the ashless dispersant that it uses in admixture with the other ingredients specified in the claims complexes with metal moieties from those ingredients so that the dispersant in the final product can no longer be considered “ashless.”

Exxon, on the other hand, urges that the trial judge’s instruction reflects the proper claim interpretation that ashless dispersant identifies a starting ingredient, and under that interpretation, it does not matter what complex forms between metal and the dispersant.

The majority opinion interprets the claims somewhere between the interpretations of Exxon and Lubrizol, as covering any mixed product — final or otherwise — in which the five ingredients specified in the claims exist in the claimed amounts. The majority accepts Lubrizol’s proof that at least some ashless dispersant is converted to nonashless dispersant during production of Lubrizol’s products, and because of that, proving that the required amounts of the five ingredients were mixed is not enough to prove infringement. Consequently, to show infringement, the majority believes that it was Exxon’s burden to prove that, at some point during production of Lubrizol’s products, the mixing *1565pot contained the claimed amounts of “ash-less dispersant” and the other four claimed ingredients. And, the majority concludes, Exxon has not introduced enough evidence in the record to meet that burden.

I agree with the trial judge’s interpretation of the claims that one skilled in the art, upon reviewing the patent specification, claims, prosecution history, and testimony, would interpret claims 1 and 61 as covering a lubricating oil composition comprising the product resulting from a combination of the required five ingredients, in the claimed amounts, regardless of any unknown reactions, or metal complexes formed between those ingredients that occurs upon mixing. With that interpretation, literal infringement is admitted.

A. Claim Interpretation In General

To determine the meaning of claims, we must examine the patent specification, other claims, and the prosecution history. Markman v. Westview Instruments, Inc., 52 F.3d 967, 979, 34 USPQ2d 1321, 1329 (Fed.Cir.1995) (in banc). Resort to testimony of those knowledgeable in the art might also be helpful to the court inasmuch as claims are interpreted from the perspective of one of ordinary skill in the art. SmithKline Diagnostics, Inc. v. Helena Lab. Corp., 859 F.2d 878, 882, 8 USPQ2d 1468, 1471 (Fed.Cir.1988).

B. The Specification and Claims

The patent specification discusses the invention in terms of an additive for motor oil which does not interfere with the function of other additives. The particular focus is on addition of the copper compound as an antioxidant and the amount of it that is employed. Moreover, the amounts specified in the working examples and other parts of the specification are identified as the amount of the additives, not the amounts in the final product after mixing. There is no analysis anywhere in the specification of the identity of intermediate or final “eomplexation” products produced by combining the ingredients specified in the claims, or of their amounts. In light of those omissions, to say that one of ordinary skill in the art would nevertheless conclude that the proportions must be measured in the pot is divorced from reality.

The interpretation that the claims list starting ingredients is bolstered by comparing the many nonborated, ashless dispersants disclosed at columns 6-8 of the patent, and expressly included in the claims, with the one type of dispersant — the borated version of certain ashless dispersants — that the parties agree does not complex with the metal moieties from the other ingredients specified in the claims. Because the nonborated, ashless dispersants do not remain completely ashless when mixed with the other ingredients specified in the claims, under the majority’s interpretation the claims would not cover use of such dispersants if a sufficient amount thereof complexed with metal to form nonashless dispersants. Yet, it is those nonborated dis-persants to which the specification and claims are primarily directed.5 Consequently, the majority interpretation limits coverage to far fewer dispersants than indicated by the specification and claims.

Moreover, the ’890 specification does not describe nor teach the invention contemplated by the majority’s claim interpretation, i.e., it does not teach the types of dispersant, the amounts thereof, or the conditions needed to attain a composition containing — after com-plexation — the amounts of ingredients specified in the claims. Although, under the majority’s interpretation, the specification would be enabling for the claimed borated disper-sants (because they do not complex), those dispersants constitute only a small portion of the disclosed and claimed dispersants. Hence, formulating the composition as interpreted by the majority, even if within ordinary skill in the art, would require extensive experimentation not even suggested in the patent, thereby rendering the claims invalid.6

*1566C. Prosecution History

As does the specification, the prosecution history focuses on the additives as starting ingredients, not on any reaction products (and the amounts in a final or intermediate product). As an example, the Examiner’s Answer prepared with respect to appeal of the examiner’s rejection of the claims in Application Ser. No. 362,114 (which was the grandparent of Application Ser. No. 49,712, the application resulting in the ’890 patent), states:

The claims are believed to be directed to the composition comprising known additives, combined at conventional levels of additions for their combined attendant functions.

And in the Reply Brief to that Examiner’s Answer, the applicants state:

The question should be whether the specific combination of additives claimed by Appellants is novel, and gives it unobvious results. The answer is the combination is novel and the combination does give unexpected results.

And elsewhere during prosecution of that application, and of SN 049,712, the examiner refers to “the various additives of the claims (dispersants ... dithiophosphates ...).”

Exxon’s interpretation is also supported by the following episode. SN 362,114 included both claim 37, which referred to a “copper compound,” and claim 38, which was to a “composition according to claim 37, said copper compound being oil soluble.” Claim 38 was rejected because it duplicated claim 37.7 The examiner took the position that the copper compound must be oil soluble — hence, “copper compound” and “oil soluble copper compound” are the same. The applicants, however, argued that “[o]ne can have a solution of a dispersant complexed with an oil insoluble copper compound, or can have an oil soluble [copper] compound” (emphasis added). Similar debate transpired during prosecution of Application SN 177, 367, the parent of SN 362,114. The Board agreed with applicants.8

The argument made during prosecution that some of the claims read on embodiments wherein the copper complexes with the ash-less dispersant is probative of Exxon’s claim interpretation as well as that of the examiner. Specifically, it shows the claim is directed to a product with “ashless” dispersant as a starting ingredient, inasmuch as some of the claims covered formation of a complex between that dispersant and metal, a formation that would render the dispersant “non-ashless”. Significantly, the examiner found no flaw in claiming a motor oil product with additives as set out in Exxon’s claim here (and I note in its foreign applications as well).

D. Other Considerations

The record includes testimony by Exxon witnesses that it is not known how copper serves as an antioxidant in the environment of the claimed composition, that certain reactions are not predictable in that environment, even though they might be predictable in a model, that it is uncertain whether zinc or phosphorus of ZDDP undergoes interaction, and in general, that no one was certain of the exact identity of the final composition or what was happening in the pot. Despite that, the majority holds applicants responsible for knowing about the formation of a *1567complex between the five ingredients required by the claims. In effect, therefore, the majority opinion penalizes applicants for not knowing or caring about exactly how their invention works.

But, “it is axiomatic that an inventor need not comprehend the scientific principles on which the practical effectiveness of his invention rests.” Fromson v. Advance Offset Plate, Inc., 720 F.2d 1565, 1570, 219 USPQ 1137, 1140 (Fed.Cir.1983); accord In re Isaacs, 347 F.2d 887, 892, 146 USPQ 193, 197 (CCPA1965). As stated in Diamond Rubber Co. v. Consolidated Rubber Tire Co., 220 U.S. 428, 435-36, 31 S.Ct. 444, 447, 55 L.Ed. 527 (1911):

And how can it take from his merit that he may not know all of the forces which he has brought into operation? It is certainly not necessary that he understand or be able to state the scientific principles underlying his invention, and it is immaterial whether he can stand a successful examination as to the speculative items involved. [Citations omitted.]

In that respect, Frank Johmann, who helped prosecute the relevant applications for Exxon, stated:

[When looking at an invention like this with a number of components, to determine infringement] ... you look at what is combined to make the product. The reason for that is that the patent law doesn’t require that you understand what happens to that final product. All that is necessary is how you obtain the result. And it is sort of like baking a cake. You mix them together. And what happens chemically in the oven, you are not concerned with. With these compositions, what happens in the engine no one really knows and it is not a consideration.

Mr. Johmann stated that he has “seen probably literally thousands of lubricant patents over the years, and this is like a standard format for a composition.” Id. Thus, claiming the composition in terms of amounts of additives is “a typical way it is done in connection with motor oil additives.” Id. Though Mr. Johmann was a patent practitioner, as opposed to a scientist skilled in the art, he adds to the record the perspective of one who has seen many patents in this field, and by shedding some light on how claims have been written in the field, he helps illuminate how one skilled in the art would read the ’890 claims.

Furthermore, when Lubrizol asked its own employee, Mr. Pindar, in 1988 to determine whether certain of its products infringed the European counterpart of ’890, he performed the analysis by comparing the starting ingredients, not the final or intermediate products. Mr. Pindar, who was a scientific advisor to Lubrizol, read the claims as a person of skill in the art would read the claims. Moreover, Dr. Salomon, a lubricant formulator working for Lubrizol, testified (although not in the specific context of interpreting claim language) that her concern as a formulator is “what goes in the pot.”

Lubrizol argues that Exxon’s omission of the word “mixture” from the ’890 claims precludes interpretation of the claims as a list of starting ingredients. This is indeed a slender reed on which to lean. “Mixture” is implied in the composition claims at issue, because by listing five “additives,” the claim implies that coverage is for a mixture of those. Thus, Exxon is claiming a “composition of matter,” which:

“... is an instrument formed by the intermixture of two or more ingredients, and possessing properties which belong to none of these ingredients in their separate state.... The intermixture of ingredients in a composition of matter may be produced by mechanical or chemical operations, and its result may be a compound substance resolvable into its constituent elements by mechanical processes, or a new substance which can be destroyed only by chemical analysis.” [Footnote omitted.]
Walker notes that “this class is a very broad one and embraces chemical compounds, mechanical or physical mixtures, alloys and a great variety of things.” [Footnote omitted.]

1 Chisum, PATENTS, § 1.02[2] at 1-10 (1995) (quoting from W. Robinson, The Law *1568of Patents for Useful Inventions 278-79 (1890)).

E. Conclusion

Lubrizol added to its motor oil the ingredients taught by the specification, and articulated in the claims, of Exxon’s ’890 patent. Lubrizol then sought to avoid infringement by arguing at trial that the claims are not literally infringed because metal ions from some of the ingredients complex with the ashless dispersant specified in the claims, converting “ashless dispersant” to nonashless dispersant. That argument was unsuccessful under the district court’s claim interpretation, but it has succeeded on appeal under the majority’s claim interpretation.

The majority and concurring opinions seem to be of the view that, if Exxon wanted to claim a lubricating oil composition formed by combining the five ingredients specified in the claims, it made a technical error in writing the claims. The majority would require a product by process claim to cover a product comprising a formula of starting ingredients even though the claim requires no particular method of mixing or particular process steps. It is not a “recipe” with specific directions for making the product. Certainly the examiner found nothing technically wrong with the claim as a list of additives for motor oil. In the view of an experienced claim drafter, Mr. Johmann, this is a standard form for such a product. I am of the view that, to one of ordinary skill in the art, the claims as written cover a product, not a method.9 Consequently, I disagree with the majority and would affirm the district court’s judgment of liability.

ll.

I would add that the majority’s reversal is an extraordinary disposition assuming its interpretation were correct. This appeal challenges the district court’s ruling on Lubri-zol’s renewed motion for JMOL under Fed. R.Civ.P. 50. The majority holds that the district court’s ruling on the merits of Lubri-zol’s motion was correct. Lubrizol’s argument for JMOL — that the claims define the final product — is rejected. If Lubrizol had attempted to advance the position of the majority in this appeal, we would have rejected the argument as outside the grounds asserted in the JMOL motions, before submission to the jury, as well as after the verdict was returned. Orthokinetics, Inc. v. Safety Travel Chairs, Inc., 806 F.2d 1565, 1579, 1 USPQ2d 1081, 1091 (Fed.Cir.1986) (“A specific reference to an issue in a motion for JNOV cannot preserve that issue for appeal where that issue was not specifically included in a motion for directed verdict made before the jury retired to consider its verdict.”); Malta v. Schulmerich Carillons, Inc., 952 F.2d 1320, 1324, 21 USPQ2d 1161, 1164 (Fed.Cir.1991) (“ ‘Fed.R.Civ.P. 50(b) allows for entry of JNOV ‘only in accordance with the party’s motion for a directed verdict.’ ”), cert. denied, 504 U.S. 974, 112 S.Ct. 2942, 119 L.Ed.2d 566 (1992).10 The issue on appeal is not the global question “What do Exxon’s claims mean?” but rather “Did the district court err in denying Lubrizol’s JMOL?” It is not unusual to see a case where a party failed to raise a defense on which it might have prevailed. However, our review of a trial court’s ruling on a motion for JMOL is *1569limited to the grounds asserted, thority of an appellate court to enter a judgment rather than remand is severely circumscribed. If no motion for JMOL on the issue is made an “appellate court [is] without power to direct the District Court to enter judgment contrary to the one it had permitted to stand.” Cone v. West Virginia Pulp & Paper Co., 330 U.S. 212, 218, 67 S.Ct. 752, 756, 91 L.Ed. 849 (1947); see also Biodex Corp. v. Loredan Biomedical, Inc., 946 F.2d 850, 854, 20 USPQ2d 1252, 1255 (Fed.Cir.1991) (“Quite clearly, the only available remedy upon finding error in a judgment entered on a jury verdict where [issue not preserved by proper JMOL] is limited to a remand for a new trial.”), cert. denied, 504 U.S. 980, 112 S.Ct. 2957, 119 L.Ed.2d 579 (1992). 11 The au-

The precedent cited by the majority for reversal is inapt. In Laitram Corp. v. Rexnord, Inc., 939 F.2d 1533, 19 USPQ2d 1367 (Fed.Cir.1991), this court agreed with the appellant’s position raised below by JMOL and on appeal. No material issue of fact prevented entry of judgment on appeal. In Jamesbury Corp. v. Litton Indus. Prods., 756 F.2d 1556, 225 USPQ 253 (Fed.Cir.1985), the JMOL was reversed on the argued grounds and the case was remanded for trial of other issues. Dana Corp. v. IPC LTd. Partnership, 860 F.2d 415, 8 USPQ2d 1692 (Fed.Cir.1988), cert. denied, 490 U.S. 1067, 109 S.Ct. 2068, 104 L.Ed.2d 633 (1989), reversed a JMOL on the ground argued below and on appeal.

The wisdom of Rule 50 cannot be gainsaid. By advocating a different interpretation of the claim sua sponte, the majority required Exxon to litigate during trial not only its opponent’s position but also the unknowable position of the appellate court. Exxon has been deprived of a jury trial on an unassert-ed and untried theory. The majority decision comes out of the blue. The majority opines that the requirement that Exxon prove infringement of a product claim does not come out of the blue, and that Exxon, therefore, is not entitled to escape the flaw of its claim drafting by a second trial. This reflects the majority’s view, not Exxon’s, that a list of additives for motor oil is an invention for a process or for a product made by a process. Exxon never asserted that its claim was for anything but a product. Without pointing to any rule set by the statute or a regulation or by the MANUAL of Patent Examining PROCEDURE, the majority decides that Exxon’s standard type of claim is poorly drafted.

The majority then states that Exxon attempted to prove infringement under the majority’s claim interpretation by evidence of what happened chemically in the pot in pre-final states. This evidence “is credited” in determining the post-trial motion. The record discloses that Lubrizol attempted to prove that its final product did not contain ashless dispersant because of what happened in the pot. Lubrizol’s theory was that its dispersant, although ashless to begin with, complexed with metal so as to become non-ashless in the final product. Exxon countered with evidence that such complexation was transient. To rule for Lubrizol, the majority must assume that the absence of proof by Exxon, for example, that for a few moments after mixing no complexation occurred — which would satisfy the majority’s claim interpretation — means that that fact could not be proved. Whether or not Exxon was precluded from such proof is debatable. That issue was not part of Exxon’s or Lubri-zol’s theory of the case. But precluded or not, there was no reason for Exxon to evaluate any intermediate product.

The majority notes its claim interpretation is broader than that of Lubrizol and, therefore, it is easier to prove infringement, but Exxon is denied that opportunity. In my view this is untenable. I read nothing in Markman v. Westview Instruments, Inc., 52 F.3d 967, 34 USPQ2d 1321 (Fed.Cir.1995) which sanctions this procedure. Markman *1570upheld a ruling on a JMOL motion. Exxon cannot conceivably have waived the issue of infringement under the majority’s broader claim construction, as the majority rules. Exxon proposed deletion of an instruction on infringement by equivalents in the final version of the instructions, but this revision occurred only after the district court adopted Exxon’s claim interpretation in its instructions. Exxon did not waive this issue in connection with Lubrizol’s or the majority’s different interpretation of the claim. The most the majority could say, as a matter of law, is that there is no possibility of proof of literal infringement. However, the question of infringement under the doctrine of equivalents is a jury question under the recent decision of this court in banc. Hilton Davis Chem. Co. v. Warner-Jenkinson Co., 62 F.3d 1512, 1520-21 (per curiam) (Fed.Cir.1995). The majority simply cuts Exxon off from its right to have the issue of infringement under the majority’s claim interpretation tried to a jury-

For the foregoing reasons, I dissent to the merits and to the procedure adopted by the majority.

. Appeal No. 94-1309 challenging the amount of damages is mooted by the majority decision.

. Paragraph 1 of 35 U.S.C. § 112 (1988) states, in relevant part: "The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains or with which it is most nearly connected, to make and use the same.... ”

. "Ashless'' denotes an absence of combined or complexed metal. Lubrizol’s Dr. Salomon testified that "it is easier from a manufacturing point of view to manufacture it in the ashless form.” She added that “[a]s a formulator, I don't care [if it is ashless or non-ashless in the product] where I have some surprising discovery that affects performance. But it doesn't matter to me.... Typically, most dispersants are made ashless from a manufacturing point of view.”

. The polymeric viscosity index improver (“PVII”) is not at issue here, inasmuch as the challenged Lubrizol products are alleged to use the ashless dispersant, not the PVII. Henceforth, this opinion will not mention PVII.

. Borated ashless dispersants are discussed at column 8, lines 43-50 of the '890 specification and are used in the four working examples. Of the 83 claims in '890, claims 7, 14-24, 30, 37-60, 65, and 72-82 specifically mention the borated, as well as other, dispersants.

. See generally Genentech, Inc. v. The Wellcome Foundation Ltd., 29 F.3d 1555, 1564-65, 31 USPQ2d 1161, 1168 (Fed.Cir.1994) (rejecting a claim interpretation that covers many inoperative permutations); Atlas Powder Co. v. E.I. duPont De Nemours & Co., 750 F.2d 1569, 1576-77, *1566224 USPQ 409, 414 (Fed.Cir.1984) (“if the number of inoperative combinations becomes significant, and in effect, forces one of ordinary skill in the art to experiment unduly in order to practice the claimed invention, the claims might indeed be invalid”); Raytheon Co. v. Roper Corp., 724 F.2d 951, 956, 220 USPQ 592, 596 (Fed.Cir.1983) ("Because it is for the invention as claimed that enablement must exist, and because the impossible cannot be enabled, a claim containing a limitation impossible to meet may be held invalid under § 112.”), cert. denied, 469 U.S. 835, 105 S.Ct. 127, 83 L.Ed.2d 69 (1984).

. Paragraph 2 of 35 U.S.C. § 112 (1988), states: "The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.”

. The Board noted that the examiner had not yet raised an "insufficient disclosure" rejection (under 35 U.S.C. § 112, ¶ 1). That rejection was subsequently raised, in the context of rejecting claims 15-17 of SN 049,712 on the specific ground of insufficient support in the specification for an oil insoluble copper compound. Those claims were eventually dropped by applicants.

. The majority, in its footnote 3, questions whether the claims as so interpreted would be literally infringed if one of the "starting ingredients” is made in situ. That issue is not before us, but it appears to me that there would be literal infringement in such a circumstance because the product formed "in situ” itself can be considered a "starting ingredient”.

. The majority does not dispute the proposition of law quoted from Orthokinetics but relies on an alternative ground of decision that no objection was made to the grounds stated in the post-verdict motion. In Malta, this court held that a general post-trial JMOL motion incorporated the specifics of the earlier JMOL motion. The majority finds support in Malta because the broader meaning it gives the claim than that advanced by Lubrizol is smaller than the spread between the general and specific motions in Malta. I read Malta to say that the general and specific motion in that case were the same. In any event, the majority's premise that Exxon is not prejudiced by denial of a new trial is flawed because the majority advanced a broader claim interpretation than that advanced by Lubrizol. Infringement of a narrower claim would establish infringement of a broader claim to the same invention, but the converse is not true. Failure to prove infringement of the narrower claim does not establish non-infringement of the broader claim.

. Fed.R.Civ.P. 50: Notes of Advisory Committee on Rules (1991 Amendment) state:

The second sentence of paragraph (a)(2) does impose a requirement that the moving party articulate the basis on which a judgment as a matter of law might be rendered. The articulation is necessary to achieve the purpose of the requirement that the motion be made before the case is submitted to the jury, so that the responding party may seek to correct any overlooked deficiencies in the proof.